Updated: Aug 5, 2019
1. COLLECTION OF INFORMATION.
We collect, process, and use your information when you:
- Register for our Services or sign in to an existing account
- Visit our Website(s)
- Access our Services through our application(s)
- Connect to our Services using third-party accounts, such as your email, social media, or payment account(s)
- Contact us for support
- Participate in our shopping or influencer programs
- Enter a sweepstakes, contest, promotion, survey, or poll
Automatically collected information
Company and third-party analytics services on our Website and apps automatically collect information about users through:
(We and our service providers automatically collect certain information about you through: )
- Interaction with our Services
- Cookies and other tracking technologies
- Location-identifying technologies
- Monitoring and analyzing trends, usage, and activities
The types of information you provide may include Personal Information. "Personal Information" means information that can be used to identify you (whether alone or in combination). The Personal Information you may provide to us includes:
- First and last name
- Email address
- Mailing address
- Phone number
- Birth Date
- Payment information (such as payment account name, payment account number, payment card expiration date, and billing address)
We may also collect Personal Information and other information based on your use of the Services:
- The nature of the product or service requested or purchased
- How you connect to our Services, such as your IP address, unique device identifiers, device or session IDs, and information regarding the network and connected hardware (e.g., computer or mobile device)
- Browsing, shopping, and purchase history
- Your geolocation
- Click-stream data (the page-by-page paths you take as you browse through our Services)
2. USE OF INFORMATION WE COLLECT. WE MAY USE INFORMATION ABOUT YOU IN THE FOLLOWING WAYS:
Manage Your Account
If you provide us with Personal Information, we may use it to: (i) process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs; (ii) monitor and manage your account; (iii) track your shopping, deliver you any rewards or payments, and identify opportunities for rewards and/or offers; (iv) send you technical notices, updates, security alerts, and administrative messages; (v) provide you customer service regarding your account and reply to your questions, comments and requests; and (vi) comply with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that the Company operates in. We may also use your information to assess risk and prevent fraud.
Improve Our Services
We may process information through analyzing and monitoring usages and trends and performing statistical analyses to improve our Services and the websites, applications, marketing efforts, and the products and services of our affiliates to provide a better service to you in the future. We may also use this information to adapt Service content to be more likely to be of interest to you.
Provide You Marketing Information
To provide you more personalized offers and/or special offers, discounts and similar information, Company may send you newsletters, rewards, discounts, promotion codes, events, and general information about the Service if you consent. To match your profile and interest, we may create a profile of your preferences and provide advertisements, content or features. You can manage these communications in accordance with Section 4 (Your Choices) below.
Administer Contests, Sweepstakes, and Promotions
From time to time, Company may invite you to enter various contests, sweepstakes, surveys or promotions. If you choose to participate in a contest or promotion, your Personal Information may be used to administer the contest, such as to determine your eligibility for the contest or to award a prize.
3. SHARING OF INFORMATION.
We may share the information we collect, including your Personal Information, with third parties under the following circumstances.
Service Providers and Business Partner
We do not sell your Personal Information and only share it with third parties to operate our Services. We may share your Personal Information with our service providers that perform marketing services and other business operations on our behalf, under our instructions and in compliance with appropriate technical and organizational security measures to protect your data. For example, we may partner with other companies to provide you support services, authentication services, prevent fraud on our Services, administer our promotions, referral programs, sweepstakes, and surveys, perform analytics, maintain the accuracy of our databases, facilitate your travel reservations, fulfill your product purchases, and administer your rewards or payments. We will not sell your Personal Information, but we may rent, sell, and share other information that cannot be used to identify you with merchant partners, third parties, or affiliates. Information that we may rent or sell will not include your Personal Information and will not include payment information.
Protection of Rights and Other Legal Purposes
We may share the information we collect, including Personal Information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal process or if in our good faith opinion such disclosure is required or permitted by law; (ii) at the request of governmental authorities conducting an investigation, including, but not limited to, meeting law enforcement requirements; (iii) to defend our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of us or any third party.
In the event of any an actual merger, purchase, sale (including a liquidation, realization, foreclosure, or repossession), or any other type of acquisition of all or any portion of Company assets, conveyance or transfer of all or a portion of our business to another company the information we collected, including Personal Information, may be shared with the new partner and/or business.
4. YOUR CHOICES
You have the right to “opt in” and “opt out" of providing us information. However, your choice to not provide information may impact your use of certain features or services. You may unsubscribe or opt out of receiving marketing emails from us by using the unsubscribe link on the footer of our marketing emails, by logging into your account settings, or by contacting us at firstname.lastname@example.org. At your request, we will provide you with information on whether we hold any Personal Information. We encourage you to maintain the accuracy of the information you submit to us, such as the information you provide us to register for your account. The Services may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through your account settings. You may provide account updates and changes by logging into your account and changing settings or by using the Contact Us option through the Services. With respect to our mobile and other applications, you can prospectively stop all collection of information by the application by uninstalling the application. You may at any time opt out from further allowing us to have access to your mobile location data by adjusting the permissions in your mobile device. We will make good-faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. We will respond to your requests within a reasonable timeframe.
5. RIGHTS APPLICABLE TO EU USERS
Legal basis for using your Personal Information
If you are a visitor from the European Economic Area (“EEA”), our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. For the European Economic Area, there are different legal bases that we rely on to use your Personal Information, namely:
- Performance of a contract. The use of your Personal Information may be necessary to perform the terms and conditions or other policies under which we provide our Services.
- Legitimate interests. We may use your Personal Information for our legitimate interests to improve our Services, security purposes, and fraud prevention, and to share information with our affiliates for internal administration. In such circumstances it is for us to ensure that these interests are not overridden by your data protection interests or fundamental rights and freedoms. If we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), this interest will normally be for to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
Choices under EU law
If your Personal Information is subject to the protections offered by EU law, you may:
- Access, correct, update or request deletion of your Personal Information, at any time by contacting us using the contact details provided under the "Contact Us" section below;
- Object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information;
- Withdraw your consent at any time if we have collected and process your Personal Information with your consent;
- Complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including US and Canada) are available here.)
To exercise any of these rights please contact us in accordance with the contact details set forth below in Section 14 below. Please note that if you are not subject to EU law, these rights do not apply to you.
6. DATA SECURITY AND RETENTION.
We take reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We use a secure, encrypted connection (using a TLS protocol) on all pages where you access or transmit Personal Information. Although Company uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Company cannot guarantee the security of your information collected through our Services. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. We retain Personal Information collected from a User via our Services for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. After that time, we may aggregate the data and retain it for analytical purposes. We may also retain your information on backup media for a period of 7 years to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.
7. PROMOTIONAL COMMUNICATIONS.
By signing up for an account, you may receive periodic emails from Company. If you consented to receiving promotional email communications, you can opt out of receiving such communications from us at any time by (i) following the instructions provided in those communications; (ii) modifying your Email Preferences in the Account Settings of your account; or (iii) contacting us through the Services. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us. Company mobile applications, browser extensions, and websites may send you notifications, such as alerts, sounds, and icon badges. Push notifications or in-app messages may include both operational messages and promotional messages regarding products, services, and offers that may be of interest to you. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device. As with emails, even if you opt out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.
9. ANALYTICS, TARGETING, TRACKING.
10. THIRD-PARTY DATA.
11. SOCIAL FEATURES.
12. REFERRAL PROGRAMS.
Company may offer features which allow you to inform an individual about our Services. If you choose to use our referral features, we will ask you for your referral’s email address to send them an electronic communication inviting them to join our Services. Company will store this information for the sole purpose of sending this email and tracking the success of our referral program. If you choose to participate in our referral programs, you represent and warrant that you have a personal relationship with your referral and that you are authorized to share their information with Company for the purpose of sending this communication to invite them to join the Services. If you believe that one of your contacts has provided us with your Personal Information and you would like to request that it be removed from our database, please contact us at email@example.com.
14. CONTACT US.